Case Digest (G.R. No. 177583)
Facts:
Lourdes Baltazar and Edison Baltazar v. Jaime Chua y Ibarra, G.R. No. 177583, February 27, 2009, the Supreme Court Third Division, Chico‑Nazario, J., writing for the Court.Petitioners Lourdes Baltazar and Edison Baltazar were private complainants in criminal prosecutions arising from the fatal shooting of Ildefonso Baltazar and the wounding of Edison. The City Prosecutor initially filed amended informations in the Manila RTC (Branch 27, Judge Edgardo P. Cruz) charging Jaime Chua (Jaime) and Jovito Armas, Jr. (Jovito) with murder and frustrated murder. On petitioners’ motion for reinvestigation, the City Prosecutor, after review, found probable cause for murder and frustrated murder (Resolution dated 2 July 1997), and Judge Cruz admitted amended informations on 9 September 1997.
The Secretary of Justice, however, on 20 October 1997 modified the City Prosecutor’s resolution: he directed the City Prosecutor to amend the informations to homicide and frustrated homicide as to Jovito and to drop Jaime from the charges. The City Prosecutor filed a Manifestation and Motion to withdraw the murder informations and to admit new informations for homicide and frustrated homicide, which Judge Cruz granted in an Order dated 18 November 1997 pursuant to Sec. 14, Rule 110, Revised Rules of Court.
Petitioners moved for reconsideration before Judge Cruz and, after the cases were re‑raffled to RTC Branch 37 (Judge Vicente A. Hidalgo), Judge Cruz declined further action and advised petitioners to file appropriate motions before the branch now exercising jurisdiction. Petitioners then filed, before Judge Hidalgo, a Motion for the Amendment of the Informations (filed 30 April 1998), seeking reinstatement of the murder and frustrated murder informations against both Jaime and Jovito.
After evaluating the prosecution’s and defense’s papers, Judge Hidalgo issued an Order dated 7 December 2004 reinstating the informations for murder and frustrated murder and directing the prosecutor to file amended informations against Jovito and Jaime. Judge Hidalgo grounded his decision on his own assessment of the affidavits and documentary evidence, finding prima facie evidence of treachery and of Jaime’s liability as principal by induction.
Jaime petitioned the Court of Appeals for certiorari and prohibition. In a Decision dated 24 January 2007, the Court of Appeals (del Castillo, J.) granted Jaime’s petition, holding that Judge Hidalgo acted in grave abuse of discretion amounting to excess of jurisdiction because (a) the situation did not present a motion to...(Pro-only)
Issues:
- May the trial court review the Secretary of Justice’s finding on the existence of probable cause and substitute its own judgment thereon?
- Did Judge Hidalgo commit grave abuse of discretion or excess of jurisdiction in ordering the reinstatement of the informations for murder a...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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